Inconvenient forum under UCCJEA - published opinion from Ky Court of Appeals

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Mother and Father were divorced in Kentucky. Mother subsequently relocated with minor child to North Carolina. The North Carolina court heard several custody and parenting time issues, after which Father challenged the Court’s jurisdiction. Pursuant to the UCCJEA, Kentucky found that it would be “an inconvenient forum and relinquished jurisdiction to the North Carolina courts.” Father appealed.


The Court of Appeals reviewed under the abuse of discretion standard holding that the Kentucky family court did not abuse its “broad discretion” by concluding that Kentucky was an inconvenient forum when the child had not lived in Kentucky since the age of 2, the child’s school and residence are in North Carolina, and no significant visitation had occurred in Kentucky.


Digested by Elizabeth M. Howell